We (the Future of Privacy Forum - FPF) are agreed that privacy policies are a failure as a consumer communication tool.
That is why we helped pioneer the use of privacy icons on the internet, particularly with online advertising.
But a privacy policy is a must for any sort of accountability as privacy enforcement is limited unless a company has made a public formal commitment that the FTC can hold them to. And as all of us who have drafted privacy policies know, the process of doing so forces you to actually map in detail practices that you may not have otherwise fully documented.
And until you know what you are doing, you can't possibly start to communicate about it.
So creating a privacy policy is step ONE.
Of course you can't stop there, you need to figure out how to communicate the key elements to users.
For many mobile apps today, that isn’t easy, given space constraints and the fact that the mobile platforms manage some key parts of the process.
For example, Apple and Android properly ensure that Apps don’t obtain user location without giving affirmative consent. However, since Apple and Google manage this process, an application developer (in the application) doesn’t have an easy way to explain until later why the application wants location and what it will do with it.
We believe that lots of work to be done here.
So when applications do have privacy policies, FPF will come back and assess how well they are doing at taking the key points and communicating them clearly to the user.
The FTC has just kicked off a new look at its Dot Com Disclosures for Advertising guidance so they are following this issue closely and are in particular looking at apps and the mobile space.
So don’t wait for our next survey! Our new site for developers, www.applicationprivacy.org, should provide some assistance.
Feedback is much appreciated.
Shaun Dakin
Fellow
The Future of Privacy Forum
Application Privacy Project
Techdirt has not posted any stories submitted by ShaunDakin.
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Privacy Policies are a good first step
We (the Future of Privacy Forum - FPF) are agreed that privacy policies are a failure as a consumer communication tool.
That is why we helped pioneer the use of privacy icons on the internet, particularly with online advertising.
But a privacy policy is a must for any sort of accountability as privacy enforcement is limited unless a company has made a public formal commitment that the FTC can hold them to. And as all of us who have drafted privacy policies know, the process of doing so forces you to actually map in detail practices that you may not have otherwise fully documented.
And until you know what you are doing, you can't possibly start to communicate about it.
So creating a privacy policy is step ONE.
Of course you can't stop there, you need to figure out how to communicate the key elements to users.
For many mobile apps today, that isn’t easy, given space constraints and the fact that the mobile platforms manage some key parts of the process.
For example, Apple and Android properly ensure that Apps don’t obtain user location without giving affirmative consent. However, since Apple and Google manage this process, an application developer (in the application) doesn’t have an easy way to explain until later why the application wants location and what it will do with it.
We believe that lots of work to be done here.
So when applications do have privacy policies, FPF will come back and assess how well they are doing at taking the key points and communicating them clearly to the user.
The FTC has just kicked off a new look at its Dot Com Disclosures for Advertising guidance so they are following this issue closely and are in particular looking at apps and the mobile space.
So don’t wait for our next survey! Our new site for developers, www.applicationprivacy.org, should provide some assistance.
Feedback is much appreciated.
Shaun Dakin
Fellow
The Future of Privacy Forum
Application Privacy Project
Techdirt has not posted any stories submitted by ShaunDakin.
Submit a story now.
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